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#509716 - 03/07/06 09:57 PM large deposits concerns
beegee Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,096
South
We have a customer in a largely hispanic community who has been bringing in large deposits averaging $25-30 thousand for the last three months. She is sending these funds via ACH to Sigue Corp which is a money remittance services provider providing international money transfer services to Mexico and Latin America. We are assuming she is taking money on behalf of members of the hispanic community and sending back home to their families.

What concerns/questions should I have with this?

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BSA/AML/CIP/OFAC Forum
#509717 - 03/07/06 10:04 PM Re: large deposits concerns
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
It sounds as if your customer is acting as an agent for an MSB and you should document her relationship accordingly. I don't find anyplace where Sigue lists its agents, but she should be able to provide you with documentation if she is and you need to do a considerable amount of analysis regarding the potential risk this customer poses in connection with BSA/AML compliance.

This needs to be taken care of promptly.
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#509718 - 03/07/06 10:13 PM Re: large deposits concerns
beegee Offline
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Joined: Feb 2004
Posts: 1,096
South
thanks for the reply - she is not an agent of Sigue - just a retail customer of the bank.

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#509719 - 03/07/06 10:27 PM Re: large deposits concerns
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
If she is an indiviudal, how is she executing the ACH transactions?
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#509720 - 03/08/06 12:46 AM Re: large deposits concerns
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
She may not have their sign in the window, but she is acting as their agent. She is probably calling in the wires by phone and Sigue is originating the ACHs or she is using "Web Wire" via the Internet and originating them herself. Rather than speculate regarding an array of possibilities, you need to ask her to come in and talk to you and explain what's going on so you can start your process for documenting or closing the account.

If necessary, tell her you will not accept any more deposits until she does.

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#509721 - 03/08/06 01:21 PM Re: large deposits concerns
blue Offline
Platinum Poster
Joined: Jul 2005
Posts: 793
We had a similar situation and could not get a straight answer from our customer. I called their version of Sigue and asked for a location in our area where I could access one of their agents. They recommended our customer. That provided us with leverage to get better responses from our customer. You might call Sigue as an individual seeking information and see what you learn.

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#509722 - 03/08/06 01:52 PM Re: large deposits concerns
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
It sounds as if you definitly have an MSB as a customer, which should raise several concerns for you. She will certainly have to provide a copy of the agent agreement with Sigue, outline to you what her AML compliance program consists of (haha), etc. You will then need to decide if you will keep the account and, if so, what monitoring will need to be done on an ongoing basis. You will also need to look at your bank's policies to see if you can maintain an account for an MSB. I would also look at the questions that your new accounts folks asked the customer and what her responses were.

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#509723 - 03/08/06 02:29 PM Re: large deposits concerns
Gischenaxim Offline
New Poster
Joined: Feb 2006
Posts: 15
we have found that many of these people have such a fear of ''government or law enforcement'' that they kept avoiding our attempts to get inforamtion.

eventually we were put in contact with their attorney or accountant and they understood and helped us. for one the son was able to explain the process.

but just talking to the owner doesn't always work. you need to remain presistent and ask if they have anyone they would trust that we could work thru.

it was easy after that

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